Trials@uspto.gov
`571.272.7822
`
`
`
`
`
` Paper No. 9
`Entered: May 4, 2018
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`NECKSGEN, INC.,
`Petitioner,
`v.
`SIMPSON PERFORMANCE PRODUCTS, INC.,
`Patent Owner.
`____________
`
`Case IPR2018-00133
`Patent 9,351,529 B1
`____________
`
`
`Before MICHAEL W. KIM, BART A. GERSTENBLITH, and
`JASON W. MELVIN, Administrative Patent Judges.
`
`GERSTENBLITH, Administrative Patent Judge.
`
`
`DECISION
`Denying Institution of Inter Partes Review
`35 U.S.C. § 314(a)
`
`
`
`
`
`
`
`
`
`571.272.7822
`
`
`
`
`
` Paper No. 9
`Entered: May 4, 2018
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`NECKSGEN, INC.,
`Petitioner,
`v.
`SIMPSON PERFORMANCE PRODUCTS, INC.,
`Patent Owner.
`____________
`
`Case IPR2018-00133
`Patent 9,351,529 B1
`____________
`
`
`Before MICHAEL W. KIM, BART A. GERSTENBLITH, and
`JASON W. MELVIN, Administrative Patent Judges.
`
`GERSTENBLITH, Administrative Patent Judge.
`
`
`DECISION
`Denying Institution of Inter Partes Review
`35 U.S.C. § 314(a)
`
`
`
`
`
`
`
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`I.
`
`INTRODUCTION
`
`Background
`
`NecksGen, Inc. (“Petitioner”) filed a Petition (Paper 2, “Pet.”)
`requesting institution of inter partes review of claims 1–19 of U.S. Patent
`No. 9,351,529 B1 (Ex. 1001, “the ’529 patent”). Simpson Performance
`Products, Inc. (“Patent Owner”) filed a Corrected Preliminary Response
`(Paper 8).1
`Pursuant to 35 U.S.C. § 314(a), an inter partes review may not be
`instituted “unless . . . the information presented in the petition . . . and any
`[preliminary] response . . . shows that there is a reasonable likelihood that
`the petitioner would prevail with respect to at least 1 of the claims
`challenged in the petition.” 35 U.S.C. § 314(a).
`For the reasons given below, on this record, Petitioner has not
`established a reasonable likelihood that it would prevail in showing the
`unpatentability of at least one of claims 1–19 of the ’529 patent.
`Accordingly, we do not institute an inter partes review of the ’529 patent.
`
`Related Proceedings
`
`The ’529 patent is the subject of three pending district court cases, one
`of which involves Petitioner. Pet. 2–3; Paper 5, 1–2.
`
`Real Parties in Interest
`
`The Petition identifies “NecksGen, Inc.” as the real party in interest.
`Pet. 2. Patent Owner identifies itself, “Simpson Performance Products,
`Inc.,” as the sole real party in interest. Paper 5, 1.
`
`
`1 In response to Patent Owner’s unopposed request, we authorized Patent
`Owner to file, inter alia, a corrected preliminary response on March 22,
`2018.
`
`2
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`The Asserted Grounds of Unpatentability
`
`Petitioner challenges the patentability of claims 1–19 of the
`’529 patent on the following grounds:
`
`References
`Hubbard ’5102 and Ashline ’3603
`Hubbard ’510, Ashline ’360,
`Ashline ’6694
`Hubbard ’510, Ashline ’360,
`Ashline ’669, and Moloney5
`Hubbard ’510, Ashline ’360, and
`Hubbard ’5666
`Hubbard ’510, Ashline ’360, and
`Moloney
`Hubbard ’510, Ashline ’360,
`Ashline ’669, and Hubbard ’566
`Hubbard ’510, Ashline ’360,
`Hubbard ’566, and Moloney
`
`Basis
`§ 103(a)
`§ 103(a)
`
`§ 103(a)
`
`§ 103(a)
`
`§ 103(a)
`
`Claim(s) challenged
`1
`2
`
`3
`
`4
`
`5–7
`
`§ 103(a) 8, 9, 11–15, and 17–19
`
`§ 103(a)
`
`10 and 16
`
`Petitioner supports its Petition with a Declaration by Dr. Jingwen Hu,
`dated October 25, 2017 (Ex. 1002).7 Patent Owner supports its Preliminary
`Response with a Corrected Declaration by Mr. Hubert Gramling, dated
`March 10, 2018 (Ex. 2001).
`
`
`2 U.S. Patent No. 4,638,510, issued January 27, 1987 (Ex. 1005).
`3 U.S. Patent No. 6,871,360 B1, issued March 29, 2005 (Ex. 1008).
`4 U.S. Patent No. 6,931,669 B2, issued August 23, 2005 (Ex. 1009).
`5 U.S. Patent No. 6,810,535 B1, issued November 2, 2004 (Ex. 1007).
`6 U.S. Patent No. 6,009,566, issued January 4, 2000 (Ex. 1006).
`7 Petitioner filed a Corrected Exhibit 1002 on November 13, 2017. We refer
`to the corrected exhibit as “Exhibit 1002” or “Ex. 1002.”
`
`3
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`The ’529 Patent
`
`The ’529 patent is directed to “safety devices worn by a driver when
`operating a high-performance vehicle.” Ex. 1001, 1:14–15. In particular,
`the ’529 patent
`relates to a restraint device that controls movement of, and
`reduces forces applied to, a driver’s head, neck and spine when
`the driver is subjected to high acceleration and vibration forces,
`such as those forces that may occur during a drag race, and also
`when the driver is subjected to deceleration forces that occur
`during a collision event.
`Id. at 1:16–22. Figure 1 is reproduced below:
`
`
`Figure 1 of the ’529 patent “is a perspective view of an embodiment of a
`multipoint tethering system in use with a head and neck restraint device.”
`Id. at 2:12–14.
`
`4
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`The ’529 patent explains that “[t]he tethering system includes at least
`one tether (rear, side and front tethers 18, 19, 21 are illustrated [in Figure 1])
`for attaching a helmet 20 to the restraint device 10 and/or a seat belt
`assembly 100.” Id. at 5:64–67. “[S]upport member 12, in conjunction with
`the various straps and anchor(s), control the head and neck of the driver
`during a collision event and offset a portion of the associated forces.” Id. at
`6:9–12. The ’529 patent teaches:
`[Q]uick release clips 40 provide releasable attachment to
`D-rings 42 mounted on the helmet 20. This arrangement allows
`for the restraint device 10 to be quickly released from the
`helmet 20 by pulling clip lines 44 (FIG. 3), thereby opening the
`quick release clips 40 for detachment from
`the helmet
`D-rings 42.
`Id. at 9:51–56.
`
`Illustrative Claim
`
`Claims 1, 8, and 14 are the independent claims challenged in this
`proceeding. Claim 1 is illustrative of the claimed subject matter and is
`reproduced below:
`1.
`A restraint device having a system of tethers, and a helmet
`cooperating with the tethers, for controlling a driver’s head
`during operation of a vehicle, comprising:
`a pair of side tethers, each of the side tethers for attachment
`to a respective side of the helmet and to a support member;
`at least one rear tether attached to the support member and
`for attachment to the helmet; and
`wherein the at least one rear tether and one of the pair of
`side tethers are jointly attached to the helmet at a single
`attachment point on each respective side of the helmet.
`Ex. 1001, 11:39–49.
`
`5
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`CLAIM CONSTRUCTION
`II.
`We do not need to construe expressly any claim terms for purposes of
`this Decision. See Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d
`795, 803 (Fed. Cir. 1999) (only terms that are in controversy need to be
`construed, and these need be construed only to the extent necessary to
`resolve the controversy).
`
`III. ANALYSIS
`
` Obviousness
`The U.S. Supreme Court set forth the framework for applying the
`statutory language of 35 U.S.C. § 103 in Graham v. John Deere Co. of
`Kansas City, 383 U.S. 1, 17–18 (1966):
`Under § 103, the scope and content of the prior art are to be
`determined; differences between the prior art and the claims at
`issue are to be ascertained; and the level of ordinary skill in the
`pertinent art resolved. Against this background, the obviousness
`or nonobviousness of the subject matter is determined. Such
`secondary considerations as commercial success, long felt but
`unsolved needs, failure of others, etc., might be utilized to give
`light to the circumstances surrounding the origin of the subject
`matter sought to be patented.
`As explained by the Supreme Court in KSR International Co. v. Teleflex
`Inc.:
`
`Often, it will be necessary for a court to look to interrelated
`teachings of multiple patents; the effects of demands known to
`the design community or present in the marketplace; and the
`background knowledge possessed by a person having ordinary
`skill in the art, all in order to determine whether there was an
`apparent reason to combine the known elements in the fashion
`claimed by the patent at issue. To facilitate review, this analysis
`should be made explicit.
`
`6
`
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`IPR2018-00133
`Patent 9,351,529 B1
`
`550 U.S. 398, 418 (2007) (citing In re Kahn, 441 F.3d 977, 988 (Fed. Cir.
`2006) (“[R]ejections on obviousness grounds cannot be sustained by mere
`conclusory statements; instead, there must be some articulated reasoning
`with rational underpinning to support the legal conclusion of
`obviousness.”)). “Whether an ordinarily skilled artisan would have been
`motivated to modify the teachings of a reference is a question of fact.”
`WBIP, LLC v. Kohler Co., 829 F.3d 1317, 1327 (Fed. Cir. 2016) (citations
`omitted).
`
`Level of Ordinary Skill in the Art
`
`Petitioner contends that a person of ordinary skill in the art would
`have had:
`at least a bachelor’s degree in mechanical engineering,
`automotive engineering, or biomedical engineering or other
`similar type of engineering degree, combined with at least two
`(2) years of experience in the field of automotive safety
`restraints, or three (3) to four (4) years of experience working in
`the head and neck restraint industry.
`Pet. 7 (citing Ex. 1002 ¶¶ 27–31). Patent Owner does not dispute
`Petitioner’s proposed level of ordinary skill in the art for purposes of this
`proceeding. Prelim. Resp. 12 (citing Ex. 2001 ¶ 31).
`Consistent with the level of ordinary skill in the art reflected by the
`prior art of record, we adopt the level of ordinary skill in the art as agreed
`upon by the parties for the purposes of this Decision. See Okajima v.
`Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d
`1573, 1579 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978).
`
`7
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`Scope and Content of the Prior Art
`
`For purposes of this Decision, we need only address the scope and
`content of Hubbard ’510 and Ashline ’360 in detail.
`
`Hubbard ’510
`
`Hubbard ’510 is directed to “a neck protection device for use by
`drivers or other occupants of high performance vehicles including cars, boats
`and aircraft to reduce fatigue or injury.” Ex. 1006, 1:7–10. The neck
`production device “includes a yoke which fits over the shoulders and chest
`of the occupant under shoulder harnesses with a high collar on the yoke and
`with a set of tethers for attachment between the helmet and the collar.” Id. at
`1:10–15. Figures 2 and 3 are reproduced below:
`
`
`Figure 2 of Hubbard ’510 “is a front view of the neck protection device . . .
`particularly illustrating the lateral attachment of tethers (15, 15a) to the
`helmet (16) and high collar (11).” Id. at 3:11–14. Figure 3 of Hubbard ’510
`“is a back view of the neck protection device (10) shown in FIG. [2],
`particularly illustrating the attachment of the tethers (15, 15a, 15b) to the
`
`8
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`rear and lateral portions of the high collar (11) and further illustrating the
`attachment of the tethers to the helmet (16).” Id. at 3:15–19.
`Hubbard ’510 explains that neck protection device 10 “has a high
`collar 11 which is integral with a yoke 12. The yoke 12 is contoured and
`preferably padded to fit the rib cage and shoulders of” an occupant. Id. at
`4:64–67. High collar 11 has a plurality of tethers 15, 15a, and 15b attached
`to helmet 16 and mounted through first guides 20 on the upper edge of the
`high collar. Id. at 5:3–6. The other ends of the tethers are “attached to a
`second fastening means, such as on dual D-rings 21, on the lower portion of
`the collar 11.” Id. at 5:6–8.
`
`Ashline ’360
`
`Ashline ’360 is directed to “a device for controlling the forward and
`downward movement of the head and neck of a driver during a frontal crash
`of a high performance vehicle.” Ex. 1008, 1:20–25. Figure 10 is reproduced
`below:
`
`
`Figure 10 of Ashline ’360 “is a front view of . . . a head restraint device,
`illustrating front and rear tethers for attachment to an article wearable on a
`wearer’s head.” Id. at 5:19–21.
`
`9
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`Ashline ’360 explains:
`[R]estraint device 100 illustrates front tethers 102 in addition to
`rear tethers 104. The front tethers 102 extend from straps 106 at
`the front torso of the driver, for attachment to a helmet. The front
`and rear tethers 102, 104 may attach to the same helmet clips, or
`may attach to separate helmet clips.
`Id. at 8:4–9.
`
` Differences Between the Prior Art and the Claims;
`Motivation to Combine
`Claim 1
`
`Petitioner contends that the combination of Hubbard ’510 and
`Ashline ’360 would have rendered the subject matter of claim 1 obvious to
`one of ordinary skill in the art at the time of the invention. Pet. 23–26.
`Petitioner divides claim 1 into four elements, [a] through [d], as shown
`below:
`
`[a] A restraint device having a system of tethers, and a
`helmet cooperating with the tethers, for controlling a driver’s
`head during operation of a vehicle, comprising:
`[b] a pair of side tethers, each of the side tethers for
`attachment to a respective side of the helmet and to a support
`member;
`[c] at least one rear tether attached to the support member
`and for attachment to the helmet; and
`[d] wherein the at least one rear tether and one of the pair
`of side tethers are jointly attached to the helmet at a single
`attachment point on each respective side of the helmet.
`Id. at 23. Petitioner contends that Hubbard ’510 teaches elements [a]
`through [c] of claim 1 and relies upon Ashline ’360 as teaching element [d].
`Id. at 23–24. With respect to element [d], Petitioner asserts:
`Ashline ‘360 (Ex 1008) fully discloses the subject matter
`of Claim 1 element [d]. Ex 1002, ¶89. Ashline ‘360 discloses to
`
`10
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`a POSITA [person of ordinary skill in the art] the joint
`attachment of tethers on the helmet at a single attachment point
`on respective sides of the helmet. Id. More specifically,
`Ashline ‘360 teaches that two “tethers may attach to the same
`helmet clips.” Ex 1002, ¶89; Ex 1008, 8:7-8. The broadest
`reasonable interpretation of the term “attached” includes
`attachment to a helmet clip. Ex 1002, ¶76; Ex. 1001, 5:6-13.
`Id. at 24. Petitioner provides several reasons as to why one of ordinary skill
`in the art allegedly would have been motivated to combine Hubbard ’510
`and Ashline ’360. Id. at 24–26. Patent Owner contests Petitioner’s
`characterization of Ashline ’360, as well as Petitioner’s identification of
`alleged reasons to combine. Prelim. Resp. 31–33.
`As a preliminary matter, Petitioner has not shown that Ashline ’360
`teaches the subject matter of element [d] as alleged. Namely, Petitioner does
`not identify where Ashline ’360 discloses side tethers, or a rear tether and a
`side tether jointly attached to a helmet at a single attachment point, as recited
`by element [d]. Ashline ’360 expressly teaches front and rear tethers that, in
`one embodiment, “may attach to the same helmet clips, or may attach to
`separate helmet clips.” Ex. 1008, 8:7–9. Thus, Petitioner’s statement that
`Ashline ’360 “fully discloses the subject matter of Claim 1 element[d]” is
`not supported on the record. See Pet. 24.
`We address each of Petitioner’s alleged reasons to combine the
`teachings of Hubbard ’510 and Ashline ’360. First, Petitioner contends that
`both references teach how to protect a race-car driver during a “declaration
`event,” e.g., a front-end collision, by using head-and-neck protection devices
`consisting of “anchors, tethers, and a helmet ‘for controlling the forward and
`downward movement of the head and neck of a driver during a frontal crash
`of a high-performance vehicle.’” Id. (citing Ex. 1002 ¶ 90) (quoting
`
`11
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`Ex. 1008, 1:23–25). Additionally, Petitioner notes that Ashline ’360
`identifies later work by the inventor of Hubbard ’510 (i.e., Hubbard ’566) as
`being in the same field as the invention disclosed in Ashline ’360. Id. at 24–
`25 (citing Ex. 1002 ¶ 90; Ex. 1008, 1:36–2:29); see id. at 25 (relying on
`Dr. Hu’s opinion that the helmet and tethers of Hubbard ’510 and
`Ashline ’360 have a similar structure and function).
`Petitioner’s identification of alleged similarities between
`Hubbard ’510 and Ashline ’360, in terms of the relatedness of their
`teachings, establishes that the references are in the same field of endeavor
`(i.e., head/neck restraints for drivers of high performance vehicles) and
`potentially directed to addressing similar problems. Being in the same field
`of endeavor and/or addressing similar problems, however, does not provide
`a reason with a rational underpinning as to why one of ordinary skill in the
`art would have modified Hubbard ’510 to attach a side and rear tether to the
`same helmet clip. Additionally, that Ashline ’360 points to a different
`reference, Hubbard ’566, as being in the same field of endeavor similarly
`fails to provide a reason as to why one of ordinary skill in the art would have
`modified Hubbard ’510 in the manner proposed by Petitioner.
`Second, Petitioner contends that “[t]he ‘529 Patent contemplates that
`its tethers would be used with other restraint devices by stating that the
`disclosed ‘restraint device 10 . . . is only an example of one of the many
`different head and neck restraint devices the tethering system may be used
`with.” Pet. 25 (citing Ex. 1001, 5:53–55). Patent Owner challenges
`Petitioner’s argument as based improperly on the ’529 patent, using the
`inventor’s own disclosure against Patent Owner. Prelim. Resp. 32.
`
`12
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`We agree with Patent Owner. It is unclear precisely what point
`Petitioner attempts to make by pointing to teachings from the ’529 patent.
`Nonetheless, we are persuaded that it is improper for Petitioner to rely upon
`the cited portions of the ’529 patent in this manner, i.e., to provide a reason
`as to why one of ordinary skill in the art would have combined the teachings
`of Hubbard ’510 and Ashline ’360. Doing so here indicates improper
`hindsight. See KSR, 550 U.S. at 421 (warning against distortion caused by
`hindsight bias and “arguments reliant upon ex post reasoning”).
`Third, Petitioner asserts that one of ordinary skill in the art would
`have had a reasonable expectation of success in combining Hubbard ’510
`and Ashline ’360 “because both references disclose head and neck restraint
`devices consisting of helmets, tethers, and anchors.” Pet. 25 (citing
`Ex. 1002 ¶ 92). Petitioner’s argument as to reasonable expectation of
`success does not speak to whether one of ordinary skill in the art would have
`been motivated to make the combination/modification in the first place.
`Motivation to combine and reasonable expectation of success are “two
`different legal concepts.” Intelligent Bio-Systems, Inc. v. Illumina
`Cambridge Ltd., 821 F.3d 1359, 1367 (Fed. Cir. 2016) (citation omitted).
`“[O]ne must have a motivation to combine accompanied by a reasonable
`expectation of achieving what is claimed in the patent-at-issue.” Id.
`Fourth, Petitioner contends that, in or around October 2001, NASCAR
`mandated head-and-neck restraint devices for all racers and that the mandate
`is “a market force that would motivate a POSITA to combine prior art
`teachings, such as the yoke and helmet of Hubbard ‘510 and the joint
`attachment of tethers in Ashline ‘360, to arrive at the head and neck restraint
`device of Claim 1.” Pet. 26 (citing Ex. 1002 ¶ 93; KSR, 550 U.S. at 421).
`
`13
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`Patent Owner counters by arguing that one of ordinary skill in the art
`would have known that Ashline ’360 “did not meet applicable specifications
`required by the sanctioning bodies and was no longer allowed to be used by
`NASCAR.” Prelim. Resp. 33 (citing Ex. 2001 ¶ 70). Thus, Patent Owner
`argues that one of ordinary skill in the art would have been motivated not to
`use any teaching from Ashline ’360, particularly the teachings regarding
`tethers. Id. (citing Ex. 2001 ¶ 70).
`“When there is a design need or market pressure to solve a problem
`and there are a finite number of identified, predictable solutions, a person of
`ordinary skill has good reason to pursue the known options within his or her
`technical grasp.” KSR, 550 U.S. at 421. Here, Petitioner alleges that
`NASCAR’s mandate provided market pressure, but Petitioner fails to
`adequately demonstrate (1) a design need or market pressure to solve a
`problem,8 (2) that there are a finite number of identified solutions, and
`(3) that the finite number of identified solutions were predictable.
`Additionally, Petitioner fails to explain why NASCAR’s mandate would
`have led one of ordinary skill in the art to combine the specific teaching of
`joint attachment from Ashline ’360 with the teachings of Hubbard ’510.
`Rather, if accepted, Petitioner’s argument would justify the combination of
`any part of any prior art head and neck restraint with any part of any other
`prior art head and neck restraint related in any way to NASCAR’s mandate.
`Petitioner fails to support such a broad proposition on the record before us.
`
`
`8 NASCAR’s mandate requiring the use of head and neck restraints does not,
`in and of itself, mean that there were problems with the head and neck
`restraints in existence at the time.
`
`14
`
`
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`IPR2018-00133
`Patent 9,351,529 B1
`
`
`Accordingly, Petitioner has not demonstrated a reasonable likelihood
`that it would prevail in showing that claim 1 of the ’529 patent is
`unpatentable.
`
`Claims 2–19
`
`Independent claim 8 recites language nearly identical to that of
`claim 1, element [d],9 and independent claim 14 recites language identical to
`claim 1, element [d].10 Ex. 1001, 12:22–24 (claim 8), 12:55–57 (claim 14).
`Claims 2–7 depend from claim 1; claims 9–13 depend from claim 8; and,
`claims 15–19 depend from claim 14. For each of the additional grounds
`challenging claims 2–19, Petitioner relies upon the combination of
`Hubbard ’510 and Ashline ’360 as meeting this claim language, and
`Petitioner offers the same reasons as to why one of ordinary skill in the art
`allegedly would have been motivated to combine the teachings of these
`references. See generally Pet. 27–62. Thus, Petitioner’s arguments with
`respect to these claims suffer from the same deficiencies discussed above.
`Accordingly, Petitioner has not demonstrated a reasonable likelihood
`that it would prevail in showing that claims 2–19 of the ’529 patent are
`unpatentable.
`
`IV. CONCLUSION
`For the foregoing reasons, on this record, Petitioner has not
`demonstrated a reasonable likelihood that it would prevail in showing that
`claims 1–19 of the ’529 patent are unpatentable.
`
`
`9 Petitioner refers to this claim language as element 8[e]. See, e.g., Pet. 30–
`31 (discussing claim 8, element [e]).
`10 Petitioner refers to this claim language as element 14[e]. See, e.g., id. at
`39 (discussing claim 14, element [e]).
`
`15
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`
`V. ORDER
`
`Accordingly, it is:
`ORDERED that the Petition (Paper 2) is denied as to the challenged
`claims of the ’529 patent; and
`FURTHER ORDERED that no inter partes review is instituted.
`
`
`
`
`16
`
`
`
`IPR2018-00133
`Patent 9,351,529 B1
`
`For PETITIONER:
`
`Luke Anderson
`ATLANTA TECHNOLOGY LAW
`(LUKE ANDERSON P.C.)
`Landerson@atltechlaw.com
`
`Minh Nguyen
`NEXT IP LAW GROUP, LLC
`Mnguyen@nextiplaw.com
`
`
`
`For PATENT OWNER:
`
`Craig N. Killen
`Karl S. Sawyer, Jr.
`NELSON MULLINS RILEY & SCARBOROUGH LLP
`craig.killen@nelsonmullins.com
`karl.sawyer@nelsonmullins.com
`ip@nelsonmullins.com
`
`
`
`17
`
`
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